Finding Text
2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over
Compliance, Questioned Costs Greater than $25k)
Federal Program Information
Federal Award Title and ALN: Research & Development Cluster, 84.031
Federal Awarding Agency: U.S. Department of Education
Federal Award ID Number: P031S210288, P031C200002
Federal Award Year: 2023
Condition: During our review of procurement testing, the College did not follow small purchase
procedures and obtain quotes to ensure the vendor with the lowest price was used for one sample.
Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal
control over the Federal award that provides reasonable assurance that the non-Federal entity is
managing the Federal award in compliance with Federal statutes, regulations, and the terms and
conditions of the Federal award. These internal controls should be in compliance with guidance in
“Standards for Internal Control in the Federal Government” issued by the Comptroller General of
the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the
micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must
be obtained.
Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history
of procurement decisions.
Cause: The College did not obtain three quotes prior to using vendor for a purchase.
Effect: The College may unintentionally use a higher-cost vendor when failing to obtain price or rate
quotations for items over the micro-purchase threshold.
Questioned Costs: Known and likely questioned costs of $32,607
Auditor recommendation: We recommend the College strengthen controls to ensure purchasing
policies and procedures are being followed and train staff in the purchasing department to comply
with all relevant federal procurement requirements.